Data Protection Privacy Policy

Last Updated: 1st February 2020
 

This data protection notice provides information about the ways in which INNOVU Insurance Ltd T/A INNOVU Insurance collects and uses personal data. For the purposes of data protection legislation, The Data Controller is INNOVU Insurance Ltd T/A INNOVU Insurance, The Arc, Drinagh, Wexford, Y35 RR92. Our Data Protection Officer can be contacted by email at: dpo@innovu.ie. “Data Controller” and “Personal Data” have the meaning given in the General Data Protection Regulations 2018.

We have appropriate safeguards in place, in accordance with our data protection obligations, for the protection of any Personal Data which we process. Our security controls are aligned to industry standards and good practice, providing a control environment that effectively manages risks to the confidentiality, integrity and availability of your information. Additionally, we ensure that our employees remain aware of our data protection obligations and are required to undertaken annual training. We take the protection of your privacy and the confidentiality of your personal information (“Personal Data”) seriously. This Notice sets out how we meet our obligations regarding data protection and the rights of our customers, prospective customers, and former customers (“Data Subjects”) in respect of their Personal Data as defined under relevant data protection legislation (including the Data Protection Acts of 1998, 2003 and 2018 [“the DPA”], the General Data Protection Regulation effective from 25 May 2018 [“the Regulation”] and any subsequent data protection legislation).

Please read this Notice carefully as this sets out how any personal data we collect from you or data that you provide will be processed.

The Regulation defines Personal Data as any information relating to an identified or identifiable natural person (a Data Subject); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or by one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.

INNOVU Insurance is committed not only to the letter of the law, but also to the spirit of the law and places high importance on the correct, lawful, and fair handling of all Personal Data, respecting the legal rights, privacy, and trust of all individuals with whom we deal.

 
1. Information we collect
 
  • Contact and Identifying information. The types of information you provide to INNOVU Insurance may include: name, date of birth, marital status, home address, contact address, email address, phone number, dependents, employment details, payment details, financial details or photo ID.
  • Claims Data (From you and any relevant third parties)
  • Health Information – Sensitive information under GDPR
  • Criminal Conviction – Sensitive Information under GDPR

When you provide personal information we will only use this information for the purposes described at point of collection e.g. providing an insurance quotation or employment application.
Special Category Data -if we collect any special categories of personal data we will ensure that we obtain your explicit consent. Special Category data includes: racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health data, data concerning a natural person’s sex life or sexual orientation and genetic/biometric data processed to uniquely identify a natural person.

Other people’s Data:

As well as collecting personal information about you, we may also use personal information about other people, for example family members you wish to insure on a policy.

NOTE: If you are providing information about another person, we expect you to show them this data protection notice and ensure that they have given you their permission to provide this information to us to enable INNOVU Insurance provide a quotation. If they have any concerns please ask them to contact us as outlined in ‘Contact us’ section.

 

2. How we collect information about you
We will collect information from you, your agents or representatives, as well as information received from:
  • insurers and their agents
  • your employer (where appropriate)
  • generally available sources such as information about you in the public domain (for example information on directors held at Companies House), online and from third party data processors (provided that it is fair to do so)
  • searches that we undertake in relation to sanctions, money laundering, and credit checks.
    This will include data that you input into our webpages, whether this is in relation to raising an enquiry with us, obtaining a quotation (even if this process is discontinued before being finished), or requesting documentation.

We will process Personal Data for and only to the extent necessary for the specific purpose(s) outlined in this document.

3. How we will use your personal information

Your Personal Data will be used to enable us to fulfil our contractual obligations in relation to your insurance cover and the provision of any ancillary risk management services

  • Provide professional services for our clients
  • Assessing your circumstances and insurance needs
  • Presenting such details to insurers for the purpose of obtaining quotations and placing cover
  • Generate quotations and process applications and proposals for the products and services we offer
  • Arranging premium finance agreements
  • Undertaking checks to guard against fraud, money laundering, bribery and other illegal activities
  • Analysing data, identifying trends, and developing and improving our services to you, helping identify ways we can improve our products and services
  • Protect your interests and defend you
  • Carry out our obligations arising from any contracts entered between you and us and to provide you with the information, products and services that you request
  • Administer the products and services that we supply to you
  • Process claims
  • To contact you if required or to respond to any communications that you might send to us.
  • We may contact customers by phone who avail of our digital platform quotations to offer support
  • To notify you about changes to our service
  • To administer our site including data analysis, testing, research, statistical and survey purposes
  • Handling Complaints
4. Legal Basis
  • To ensure that the processing of your data is lawful, such processing will only be undertaken if:
  • t is necessary for the performance of a contract to which you are or will be a party to; or
  • you have given your consent; or
  • you confirm that any personal information you give to us about another person is given with their informed consent
  • processing is necessary for compliance with a legal obligation to which we are subject; or
  • processing is necessary to protect your vital interests; or
    to perform a task carried out in the public interest or in the exercise of official authority vested in us; or
  • processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by your fundamental rights and freedoms which require protection of Personal Data, in particular where the Data Subject is a child.

We will process special category and criminal conviction data we collect about you for the performance of our contract with you, which is deemed to be necessary for reasons of substantial public interest. This allows us to quote for and provide you with insurance products and services, to process claims and renewals and to administer your policy.

Where Personal Data about you is obtained from publicly available sources, we will only use such data fairly, meaning for legitimate purposes as would be anticipated of (and reasonably expected as) the activities of an insurance broker, or employee benefits consultant as appropriate, and not further processed in a manner that is incompatible with those purposes.

 

5. Sharing your data

We may make your information available to third parties with whom we have a relationship to provide services on our behalf. We will only provide to those third parties the information that is necessary for them to perform the services and we take measures to protect your information.

The selected third parties that we may share your information with may include:

  • Your authorised representative
  • Third parties with whom we need to share your information to facilitate transactions you have requested, where you ask us to share your information
  • Service providers who provide us with support services
  • Statutory and regulatory bodies (including Central & Local Government) and law enforcement authorities
  • Third parties in connection with the sale or purchase of investment assets by us: persons making an enquiry or complaint, advice agencies and other regulated intermediaries, receivers, liquidators, examiners, official assignee for bankruptcy and equivalent in other jurisdictions including court orders
  • Trade associations and professional bodies, non-statutory bodies and members of trade associations.
  • Pension fund administrations, trustees of collective investment undertakings and pensions trustees, insurers and product producers.Healthcare professionals and medical consultants.
  • Business of joint venture partners
  • Any prospective seller or buyer of any business or assets related to the site, a INNOVU Insurance product or all or part of INNOVU Insurance
  • Any business partners, members of our corporate group, suppliers and sub-contractors for the performance of any contract we enter into with them or you.
  • If you hold insurance against a liability that may be incurred by you against a third party, where for whatever reason you cannot be found or you become insolvent, or the court finds it just and equitable to so order, then your rights under the contract will be transferred to and vest in the third party even though they are not a party to the contract of insurance. The third party has a right to recover from the insurer the amount of any loss suffered by them. Where the third party reasonably believes that you as policyholder have incurred a liability the third party will be entitled to seek and obtain information from the insurer or from any other person who is able to provide it concerning:
    • the existence of the insurance contract,
    • who the insurer is,
    • the terms of the contract, and
    • whether the insurer has informed the insured person that the insurer intends to refuse liability under the contract
6. Data Retention
Data will not be held for longer than is necessary for the purpose(s) for which it was obtained. INNOVU Insurance will process personal data in accordance with our retention schedule. This retention schedule has been governed by our regulatory body (Central Bank of Ireland) and our internal governance
 
 
7. What happens if I do not provide my data?

If you do not provide information we may not be able to:

  • Provide requested products or services to you
  • To continue to provide and/or renew existing products or services
  • Assess suitability for product/service recommendations
8. Profiling/Automatic Decision Making

Profiling;

The main categories are

  • Risk profiling.
  • Profiling for marketing purposes.
  • Establishing affordability and providing quotations for financial services 

Risk Profiling

To establish a customer’s attitude to investment risk (relates to pensions and investments) advisors have automated calculators which calculate the customer’s attitude to various levels of risk having answered a series of questions.

Profiling for marketing purposes

Where we contact you about other services, we run automated queries on our computerised data base to establish the suitability of proposed products or services to your needs. We process information you give to us and information we receive about you from other sources. Note that we do not disclose personal information about you to third parties.

Establishing affordability and providing quotations for financial services products.

  • To provide you with information about other goods and services that we offer which are similar to those that you have already purchased or enquired about
  • For occasional market research and statistical purposes. You may ‘opt out’ of participating in such market research at any time.
  • To send you offers, with your consent, for products which we feel are relevant to your needs
  • To measure or understand the effectiveness of advertising we provide to you and to deliver relevant advertising to you.
9. Opting out

We want to make it easy for you to make your own choices as to what information you receive from us and how we contact you. Therefore, whether you are an existing, former or prospective client we will always remind you of your right to opt out of future marketing related communications each time we send such correspondence to you. You can elect not to receive any marketing related communications from us at all, or request that you only receive certain types of communication. Please see below for contact details.

 
10. Your Rights regarding your Personal Data

INNOVU Insurance facilitate you, our customers rights in line with our data protection policy and the subject access request procedure which is available on request.

At any point while we are in possession of, or processing your personal data, you, the data subject, have the following rights:

  • Right of access – you have the right to request a copy of the information that we hold about you.
  • Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
  • Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
  • Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
  • Right of portability – you have the right to have the data we hold about you transferred to another organisation.
  • Right to object – you have the right to object to certain types of processing such as direct marketing.
  • Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.
  • Right to judicial review: in the event that INNNOVU Insurance refuse your request under rights of access, we will provide you with a reason as to why.

All of the above requests will be forwarded on should there be a third party involved as we have indicated in the processing of your personal data.

If you wish to exercise any of your data rights, you can contact us at INNOVU Insurance, The Arc, Drinagh, Co Wexford Y35 RR92, or at email: dpo@innovu.ie

11. Data Security

We have appropriate measures in place to ensure that users’ personal details are not misused, accidentally destroyed, lost or altered when we process your data either by electronic or paper means. Occasions will arise when customer information is passed outside Innovu Insurance to our trusted third-party suppliers, but they will only act upon instruction from Innovu Insurance in order to perform the services required.

.

12. TRANSFERRING PERSONAL DATA TO A COUNTRY OUTSIDE THE EEA

The Data Controllers may from time to time transfer (‘transfer’ includes making available remotely) Personal Data to countries outside of the EEA where this is necessary for us to provide our services to you. This will take place only if one or more of the following applies:

  • The transfer is to a country, territory, or one or more specific sectors in that country (or an international organisation), that the European Commission has determined ensures an adequate level of protection for Personal Data
    The transfer is to a country (or international organisation) which provides appropriate safeguards
  • The transfer is made with the informed consent of the relevant Data Subject(s)
  • The transfer is necessary for the performance of a contract between the Data Subject and the Company (or for pre-contractual steps taken at the request of the Data Subject)
  • The transfer is necessary for important public interest reasons
  • The transfer is necessary for the conduct of legal claims
  • The transfer is necessary to protect the vital interests of the Data Subject or other individuals where the Data Subject is physically or legally unable to give their consent; or
  • The transfer is made from a register that, under UK or EU law, is intended to provide information to the public and which is open for access by the public in general or otherwise to those who are able to show a legitimate interest in accessing the register.
 
13. Additional Processing

If we intend to further process your personal data for a purpose other than for which the data was collected, we will provide this information to you prior to processing this data.

 

14. Complaints

In the event that you wish to make a complaint about how your personal data is being processed by INNOVU Insurance or how your complaint has been handled, you have the right to lodge a complaint with our Data Protection Officer
You may also lodge a complaint with the Data Protection Commission in Ireland, whose details are:

Data Protection Commission
21 Fitzwilliam Square South
Dublin 2
D02 RD28

 

15. Contact Us

Your privacy is important to us. If you have any comments or questions regarding this notice please contact dpo@innovu.ie

We may change the privacy notice from time to time. When such a change is made, we will post a revised version online. It is your responsibility to review this privacy notice periodically to keep up to date with any changes. By using our services you agree to this privacy notice.